404a5 and brokerage accounts...

[CLE401kGuy]

Here's the setup - client has allowed it's participants to select any broker for their 401k account - in some instance, a participant even has multiple brokerage accounts... the only statements the participants are receiving are their brokerage statements - since part of the plan is on a 404a5 'ready' platform, those participants will receive the required info... it's all those other participants I'm concerned about... side note, the plan is 100% vested on all sources... any thoughts or ideas would be appreciated....

[Bird]

Doing both a platform and letting participants do whatever they want can be problematic, but assuming you've worked out those issues...

if the brokerage people can be on the platform and are getting the platform information, then that should cover the need to give them fee and performance info on at least 3 funds. If there are 5 brokerage people with the same funds and those funds are not on the platform, you are supposed to be giving fee and performance info on those funds as well.

I'd be worried about the fee disclosures for the actual brokerage account expenses - not so much the after the fact ones, which will show up on the account statements, but the "annual notice" is supposed to disclose those fees. It doesn't have to be on one document, but let's be serious, the brokerage firms aren't doing this - are you?

[Guest benji]

some comments from borzi on the issue http://www.investmentnews.com/article/2012.../FREE/120619925